ML20207S408
| ML20207S408 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 12/15/1986 |
| From: | GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | |
| Shared Package | |
| ML20207S403 | List: |
| References | |
| PROC-861215, NUDOCS 8703190404 | |
| Download: ML20207S408 (28) | |
Text
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o PLAN FOR OBTAINING APPROVAL TO RELEASE APPROXIMATELY 215 ACRES FROM GA TECHNOLOGIES INC. LICENSE SNM-696 TO UNRESTRICTED USE DECEMBER 15, 1986 B703190404 861215 PDR ADOCK 07000734 C
I.
Objective II.
Summary of Plan III.
Areas / Facilities to be Released to Unrestricted Use IV.
Investigation, Survey and Sampling Plan V.
Target Criteria for Unrestricted Release VI.
Compliance With the Target Criteria VII.
Disposition of Contaminated Soil and Vegetation VIII.
Survey and Safety Equipment IX.
Schedule for Release to Unrestricted Use X.
Background Levels XI.
References Appendix A "QA Plan" 1
I.
Objective The objective of this plan is to obtain the release of approximately 215 acres from GA Technologies Inc.'s (GA) Materials License SNM-696 to unrestricted use.
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II.
Summary of Plan GA is seeking to obtain the release of approximately 295 acres of its licensed site in San Diego to unrestricted use, leaving approximately 120 acres remaining under-the jurisdiction of NRC and State of California licenses. The release of the approximately 295 acres is being pursued by means of two plans. The first plan, which has already been approved by the NRC (References 1 and 2), addresses the release of approximately 80 acres which had contained and surrounded GA's former Waste Processing Facility.
-Work is well underway on that effort.
The second plan, described herein, addresses the release of approximately 215 additional acres.
These 215 acres consist primarily of undeveloped land, and there is no known contamination of this land. The second plan is modeled after and contains the same target criteria as the already approved first plan. Specifically. the second plan is as follows:
1.
Investigate current and past activities and identify any which may have had a potential for contaminating those portions of the site / facilities which comprise the approximately 215 acres to be released.
i' 2.
For each activity identified, if any, provide:
a.
a description of the location of the activity, b.
a brief history of the activity, and c.
a characterization of any residual radioactive materials, including a listing of the principal nuclides, and estimates of their concentrations, and total quantity.
3.
Decontaminate, if necessary, any such location to:
i a.
meet the license criteria for release of a facility or equipment to unrestricted use (Table 1), and/or b.
remove any contaminated soil and/or vegetation until the residuals meet the NRC policy (SECY 81-576) Option 1 criteria. This option assures that no individual is likely to receive an external radiation 3
exposure at a rate greater than 10 microR/ hour above background measured at one (1) meter above the surface, or 20 millirem / year to the lung or 60 millirem / year to the bone.
See Table 2, 4
Provide the NRC and State of California Radiologic Health Branch with the results of the investigation regarding past and present activities involv-ing the approximately 215 acres and the results of the final surveys.
5.
Request NRC confirmatory surveys to independently verify that the approximately 215 acres and facilities thereon meet the criteria for release to unrestricted use.
6.
Request and obtain NRC and State license amendments indicating that the approximately 215 acres and facilities thereon may be released to unrestricted use.
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TABLE'l ACCEPTAB(E S RFACE'CONTAMINiTION LEVELS 2
fl0CLl0E5s AVEMGEbcf fyllgih ti f
' REH0VABLLbef U-nat,11-236, U-230, and 2
associated decay products 5,000dpma/IDOcm 15,000 d n n/100 cm2 1.000 dra e/100 cmI i
le ansuranics, lla-22fi, Ita-220, lh-230, th-220, pa-231, 100 dpm/100 cm2 300 dpm/100 cm.2 20 d;m/100 cut Ac-227, 1-125, 1-129 ih-nat, 1h 232, Sr-90, 1000.d un/100 cle!
3000 dpm/100 cm2 200 dp=/100 ca!
Da-223 Aa-224 U-232, 1-126, l
1-131, 1-133 lieta-gann einitters (nuclides
~
istth decay niodes other than i
j alpha emission or spontaneous 5000 dpm sy/100 cni2 15,000 dpa sy/100 cet 1000 dpm sy/100 cm2 j
lission) encept Sr-90 and others noted above.
i a bere surf ace contamination by both alpha-and beta-ganina-emitting nuclidas exists, the limits established for alpha-and beta gamma-se.lttln u
nuclides should apply Independently.
l'As used in this table,'dpm (disintegrations per minute) nieans the rate of emission by railloactive esaterial as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factnit associated with the instrumentation.
C casurcrients of average contaminant should not be averagud over more than I square sieter., for oisjects of less surface area, the average li sho'sid lie derived for each such object.
d ihe maalasum cantamination level applies to an area of not more l'han 100 cat, i
'Ihe amount of remnvalite radio.letive material per 100 cn2 of surfa'ce area shuuld be determined by wiping that area with dry filter or sof t absorbent paper. applying moderato pressure, and assessing the amount of radioactive material on the selpe with an appropriate Instrusient of j
too,n efficiency. I: hen removable contamination on objects of less surface area is determined, the pertinent levels should be reduced i
proportionally and the entire surface should be wiped.
l f lhe aveiage and maximum radiation levels associated with surface contamination resulting from beta-ganesa emitters should not exceed 0.2 mrad /lr at I cm and 1.0 mrad /hp at I cm. respectively, measured througli not more than 7 milligrams per square. centimeter of 3
j total absorber.
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TABLE 2 Criteria for Soil Decentamination at the GA Site Exposure Target
- Other Existing Pathway Criteria Criteria or Guidance External Radiation 10 nr/hr 20 r/hr indoor b) EPA cleanup (whole body)
(35 mrem /yr)(,)
standard for Inactive Uranium Processing Site: 500 mrem /yr-10 CFR 20; 170 mrem /yr-FRC Guidance; 400-900 mrem /yr-Sur-geen General's Guidance for in-door exposure; 25 mrem /yr-40 CFR 190.
Inhalation of Partic-1 mrad /yr (l ulates (lung, bone)
(20 mrem /yr)gg) 1500 mrem /yr-10 CFR 20( }
25 mrem /yr-40 CFR 190 3 mrad /yr (bone) 1 mead /yr (lung), 3 mrad (bone)
(60 mrem /yr)
EPA Transuranic Guidance A
(a)This value does not include background, the 35 mrem /yr (realistic dose) includes shielding factor of 0.5 from' building a residential home for general population and residence time 80 percent.
40 CFR Part 192 - Federal Register, April 22, 1980.
Based on quality factor of 20 as originally intended for alpha emitted from the transuranic elements.
(d) Designated in : P derived from 10 CFR 20.
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III.
Areas / Facilities to be Released to Unrestricted Use The approximately.295 acres (of a total of approximately 415 acres) to be released to unrestricted use consists of:
- 1) an approximately 80-acre area associated with and surrounding GA's former waste processing facility (as mentioned above, the release of this area is being pursued under a separate, already approved plan), plus 2) approximately 215 acres of mostly raw / undeveloped land which is addressed by this plan. This approximately 215 I
acres has upon it some asphalt paving, a building housing general shipping and receiving faciliti s and other offices (e.g., a credit union), San Diego Gas &
Electric Company's Torrey Pines sub-station, a sewage treat' ment facility (known as " Callan Ponds") which has been abandoned by the City of San Diego, and a pump station to the municipal sewerage system.
The GA site boundary defining the area currently under jurisdiction of NRC and State licenses is shown in Figure 1.
The areas to be released are shown on Figure 2.
The approximately 80 acres whose release is being sought under another plan is shown and referred to as Area A.
The approximately 215 acres being addressed by this plan is shown and referred to as Area B.
None of the land or facilities associated with Area B are known to have been involved with the use or storage of radioactive material, except the central shipping and receiving facilities (i.e., Building 11) and the sewer pump station.
The shipping and receiving facilities were involved with radioactive material only to the extent that shipments and receipts of radioactive material left from and arrived at GA at this facility. Only packaged material was, and is, handled at the facility.
There is no contamination resulting from this activity.
The sewer pump station includes a holding tank and pumps for pumping the sewage into the Metropolitan Sewerage System. The pump station receives effluent from the GA main site facilities. GA releases small quantities of radioactive materials into its main site sewerage system within the limits and criteria specified by the applicable local, State of California (Reference 3) 7
and U.S. Nuclear Regulatory Commission (Reference 4) regulations. The radioactive material that is released into the GA sewerage system is diluted with the sewage from other main site facilities before it leaves the main site and empties into the holding tank at the pump station.
Following the release to unrestricted use of the approximately 295 acres associated with Areas A and B, GA will have approximately 120 acres remaining under the jurisdiction of NRC and State licenses. These 120 acres will be made up of two approximately 60-acre sites as shown on Figure 3.
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IV.
Investigation, Survey and Sampling Plan General Current and past activities involving radioactive material will be investigated to ascertain whether any activity has, or may have had, the potential for contaminating any portion of the site or facilities comprising the 215 acres to be released.
Persons familiar with GA's activities, past and present, involving radioactive material will be queried as to whether they have any knowledge of any activity which may have had the potential for contaminating the site or facilities.
If any potentially contaminated area (s) is identified, an investigation and evaluation of the area (s) will be performed to characterize the area (s) in terms of residual radioactive materials, including a listing of the principal nuclides, and estimates of the concentrations and total quantity.
For land areas, this would involve a " walkover" survey and the collection of representa-tive soil samples.
For facilities, this would involve wipe surveys as well as surveys with hand-held instrumentation.
If the results of surveys or the analyses of the soil samples or wipes indicate contamination in excess of the target criteria for unrestricted use, i.e.,
Option 1 criteria, decontamination will be conducted in order to meet the target criteria (see Section V).
An area identified as requiring decontamination will be referred to as an "affected" area.
Soil Sampling Plan For any area identified as being contaminated, soil samples will be taken to characterize the site as follows:
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o Collection a.
The surface vegetation (brush and weeds) will De removed by cutting off at ground level, not uprooted.
b.
Surface samples (0-1") will be collected; approximately 2 kilograms of 9
soil sample.
c.
A composite soil sample (1"-6" or 1"-12") will be collected based on the area and estimated depth of contamination.
d.
If subsurface soil contamination is found, then additional samples (e.g. core samples) will be taken at sufficient depths to provide an estimate of the extent of contamination.
e.
The locations where soil samples are taken will be marked and identified on a map.
o Preparation a.
The soil samples will be free of! vegetation and rocks.
b.
The samples will be dried to remove moisture.
c.
The sample will be crushed and mixed to eliminate clumping and to homogenize (clumping would be due to excess moisture).
o Analysis The samples will be analyzed by gamma ray spectroscopy, gross alpha, gross beta, DNAA or chemical analyses performed to written procedures.
If results indicate contamination levels above the Option 1 criteria, additional decontamination will be conducted in order to meet the target criteria (see Section V).
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V.
Target Criteria for Unrestricted Release Given below are the target criteria for release to unrestricted use.
These criteria are the same as those approved (Reference 2) in Ga's plan (Reference 1) for the release of the approximately 80 acres associated with and surrounding the former waste processing facility.
A.
Facility and Equipment Table l is taken from USNRC's criteria for releasing facilities and equipment to unrestricted use.
It has been incorporated into our SNM-696 license. This table will be used for releasing process equipment or buildings to unrestricted use.
The above criteria will not be utilized for soils.
B.
Direct Radiation External radiation (gamma dose rate in air one meter above ground level) shall not exceed 10 microR/hr. above background for a diffuse source area (a contaminated area greater than 30' x 30')
and shall not exceed 20 microR/hr. above background for a discrete area (a contaminated area smaller than 30' x 30').
C.
Inhalation Pathway Table 3 contains values of soil contamination (pci/gm) which if residing on the surface and could be inhaled would not lead to an exposure exceeding the Option I acceptability limit. Meeting the target criteria in Table 3 will indicate that the residuals satisfy the Option I acceptability criteria. Soil contaminations above these Table 3 values may be acceptable under unusual circumstances, but only if a specifically analyzed intrusion scenario shows that any individual will not be exposed to radiation levels greater than those appropriate for NRC/ EPA Option I.
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D.
Ingestion Pathway The GA site is located within a semi-arid region zoned for light industry and research and development.
The area is not, nor will likely be, allowed any residential or agricultural land usage.
There is no potable water on the site or its environs. A brackish water table is approximately 275-300 feet deep at about the same level as the nearby salt water backwater and marshes.
There fore,
the pathway for ingestion of any residual contamination via any food or' water is highly improbable.
However, vegetation (brush, weeds, etc.) removed from the GA site for unrestricted disposal could possibly enter the ingestion pathway. Therefore, the contamination levels of such vegetation must satisfy the target criteria for ingestion exposure (as well as the target criteria for direct radiation and inhalation exposure).
The target criteria for food ingestion exposure is 30 mrem / year to the bone (NRC Policy Issue SECY-81-576). The dose commitnent resulting from ingestion (vegetation, beef, milk) of radionuclides from contaminated vegetation are shown in Table 4 These values are based upon a unit concentration of 1 pCi/ gram of each radio-nuclide in the vegetation.
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TABLE 3 Individual Concentration in Soil Resulting in an Annual Inhalation Dose of 20 mrem to' the LungI ) and 60 mrem to the Bone ( }
Solubility Derived Concentration (pCi/g)
Radionuclide Classification Lung (20 mrem /yr)
Bone (60 mrem /yr)
U-238 Y
35 1.2 x 10" 2
U-238 W
3.2 x 10 3.9 x 10 4
3 U-238 D
1.9 x 10 1.2 x 10 U-235 Y
35 1.2 x 10 2
3 U-235 W
3.2 x 10 3.9 x 10 4
3 U-235 D
1.9 x 10 1.2 x 10 U-234 Y
30 1.0 x 10*
2 3
U-234 W
2.8 x 10 3.6 x 10 4
3 U-234 D
1.7 x 10 1.1 x 10 Th-232 Y
35 2.6 x to 2
2 Th-232 W
3.3 x 10 1.0 x 10 3
3 Ra-228 W
3.3 x 10 2.9 x 10 3
3.3 x 10l Th-228 Y
20 1.8 x 10 2
Th-228 W
1.3 x 10 Co-60*
Y 1.2 x 10*5 1.6 x 10f Co-60 W
1.2 x 10 5.8 x 10 Cs-137" 5
6 D
9.6 x 10 1.8 x 10 Sr-90" Y
1.8xtof 5
2.6 x 10 Sr-90 D
1.6 x 10 2.8 x 10 (1) Pulmonary lung (570 gm); consistent with EPA's Transuranic Guidance.
(2) Bone means osseous tissue (5,000 gm); consistent with EPA's Transuranic Guidance.
(3) The daughters of Th-228 and Ac-228 do not contribute significantly to the inhalation dose because of their comparatively short half-lives.
(4) Solubility classifications are based on ICRP-30.
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U TABLE 4 Dose Commitment Resulting from Ingestion (Vegetation, Beef, Milk) of Radio-nuclides from Contaminated Vegetation (Brush, Weeds, etc.).
Figures Based On a Unit Concentration of 1 pCi/g of Each Nuclide in the Vegetation.
Radionuclides Bone Dose (mrem /yr.)
- 5. 6E-2 (1)
Reference:
NRC's Docket No.70-820 - United Nuclear Corporation Resources Company " Soil Decontamination Criteria for the Decommissioning of the UNC's Facility." Scrap Recovery Junction, Rhode Island.
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VI..
Compliance With the Target Criteria Given below are the target criteria for direct radiation and inhalation pathways.
Both criteria must be met prior to release of an area for unrestricted use.
A.
Direct Radiation The direct radiation level of 10 microR/hr. above background is intended as a target criterion for open land cleanup. The dose limit will be measured using calibrated micro R meters accurate enough to differentiate background.
Upon completion of any required decontamination, a final survey will be made to verify all significant contamination has been removed and the area meets the target criteria.
To demonstrate compliance with the direct radiation limit, the affected areas will be divided into grids about 30' x 30' for l
surveying purposes.
In order to meet the target criterion, the following conditions have to be met:
External radiatior. (gamma dose rate in air one meter above ground level) shall not exceed 10 microR/hr.
above background for a diffuse source area (a contaminated area greater than 30' x 30') and shall not exceed 20 microR/hr. above background for a discrete area (a contaminated area smaller than 30' x 30').
B.
Inhalation of Particulates Table 3 summarizes the derived soil contamination limits for each inhaled radionuclide, which results in a committed dose of 20 mrem /yr. to the lung and 60 mrem /yr. to the bone.
It is noted that Tabla 3 soil limits are for individual radionuclides.
If a mixture i
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of these radionuclides exists in soil, the following formula will be applied to show compliance:
the sum of Ci/Li < 1 where Ci = the average soil concentration of radionuclide i, and Li = the derived maximum soil limit for radionuclide 1 (from Table 3).
To demonstrate compliance with the dose limits established for the is halation psthway, the follcwing has to be met:
Representative soil samples shall be collected from the affected area at the intersections of a 30' x 30' grid. samples shall ba taken from the first 1-inch (1") of soil and analyred for the various isotopes. If the concentration of isotopes in a sample exceeds the target criteria given in Table 3, the results of the four adjacent 30' x 30' samples can be averaged with the initial sampie's result.
If this average value is below the target criteria, compliance with the target critia will have bt'en d emonstrated.
The derived concentrations in Table 3 also apply to subsurface soil contamination. Therefore, subsurface
- soil samples will also be collected as follows.- After decontamination of an effected area has resulted in the above condition being met for surface soil, compliance with the subsurface requirement will be demonstrated by analyzing a random 5% of the subsurface soil samples.
1
'" subsurface soil sample" refers to a soil sample taken starting at a depth of 1" and extending to a depth of 6" or l' depending on the area and estimated depth of contamination.
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If a subsurface random sample exceeds the limit, the four adjacent 30' x 30' subsurface samples will be analyzed and the results averaged. If the average is below the limits, the inhalation dose target criteria will have been met.
If the averaged result is above the limits, further decontamination will be conducted.
C.
Ingestion of Vegetation (Brush, weeds, etc.)
Table 4 summarizes the derived vegetation contamination limits for each ingested radionuclide which results in a committed dose of 30 mrem / year to the bone.
The vegetation contamina' tion limits given in Table 4 are for individual. radionuclides. If a mixture of these radionuclides are present in vegetation, the following formula will be applied to demonstrate compliance:
the sum of Ci/Li < 1.0 where Ci = average concentration of radionuclide i in vegetation Li = derived limit for radionuclide i in vegetation (from l
Table 4).
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VII.
Disposition of Contaminated Soil and Vegetation Soil Soil with contamination levels above the Option 1 target criteria will be appropriately packaged and shipped to an authorized radioactive waste disposal facility.
Vegetation Vegetation (brush, weeds, etc.) with contamination levels a'bove the target criteria for external radiation or inhalation exposure or ingestion exposure (see Sections V and VI) will be appropriately packaged and shipped to an authorized radioactive waste disposal facility.
Vegetation with contamination levels below the target criteria for external radiation, inhalation exposure and ingestion exposure may be removed from the GA site for unrestricted disposal, e.g. sent to a local land fill facility.
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VIII.
Survey and Safety Equipment Work performed will be done using proper protective measures to comply with 10 CFR 20 and accepted health physics practices.
Safety equipment and health physics instrumentation on site that will be available for use, as required, includes but is not limited to:
. Anti-contamination clothing
. Personnel monitoring devices
. Respiratory protection equipment (supplied air hoods)
. Air samplers
. High Efficiency Particulate Air (HEPA) filtered vacuum cleaners
. Calibration standards for instrumentation
. Health physics instrumentation
. MicroR/hr meters (Ludlum Model 19 or equivalent)
. GM meters (Ludlum Model 3 with a Model 44-9 pancake probe or equivalent)
. Alpha survey meters (Eberline PAC 14SA or equivalent)
. Gas proportional sample counters (Ludlum Model 2200 or equivalent)
. Gamma analyzers with NaI and Ge(Li) detectors (Davidson Pulse Height Analyzer Model 4106 or equivalent) l l
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IX.
Schedule for Release to Unrestricted Use Inasmuch as it is not anticipated that any decontamination of the approximately 215 acres or facilities. thereon will be required, it is expected that the investigation and surveys will be completed in a relatively short time. More specifically, it is estimated that this effort would be completed about one month after NRC approval of this plan.
The report documenting the results of the investigation and surveys would require about one additional month to prepare, and would then be submitted to the NRC and the State.
At that time, NRC Region V would be requested to perform a final confirmatory survey.
Upon receipt of the NRC report confirming that the approximately 215 acres and facilities thereon meet the target criteria for release to unrestricted use, preparation would commence on submittals requesting the NRC and the State of California to release the subject approximately 215 acres and facilities to unrestricted use. These submittals would also request that the approximately 215 acres and facilitis thereon be removed from GA's NRC and State licenses.
Schedule Time of Completion Item Relative to Plan Approval Date NRC approval of plan 0
GA investigation and surveys
+ 1 month GA report on investigation and surveys
+ 2 months GA request NRC confirmatory survey
+ 2 months i
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s X.
Background Levels j-a The background for the general area was established by taking soil samples from five (5) selected locations agreed to by GA and the USNRC s
(Reference 1).
Surface samples (0-1") and composite samples. from between 1' and 2' depth were taken from each of the five locations.
Samples were assayed by gamma ray spectroscopy by'CA, the USNRC and Oak Ridge Associated UniversitEts. The results were compared and found to be consistent. The r'esults of Ga's analyses of soil samples are listed below:
,a-Isot6pe Conc pCi/gm K-40 21.81 Co-60 f
0.003 Cs-137 0.09 U-238 1.5 U-235 O.09 i
t Th-232 1.50 i
t Th-228 1.32 s
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O.84 Ra-228 1.3f Background external r,adiation levels will be estabidhed for the work site by taking readinss in the adjacent non-contaminstM areas and averaging them to obtain an overall background reading for the area.
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XI.
References 1.
Asmussen, K.E. letter 696-8023 to William T. Crow, " Docket 70-734:
Plan for Obtaining Release of Certain Areas to Unrestricted Use," dated October 1.
1985.
2.
Crow..N.T. letter FCUP:NK/70-734 to Keith E. Asmussen, dated November 26, 1985 (g' ave NRC approval of plan submitted by reference 1 above).
3.
California Radiation Control Regulations, Title 17, California Administrative Code, Chapter 5, Subchapter 4, Section 30287.
4 U.S. Nuclear Regulatory Commission Regulations 10 CFR 20.303.
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,c APPENDIX A W
QA PLAN
- 1. 0 Puggo.se, n,
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The purpose of the QA Plan is to establish an acceptance plan for the
- survey, evaluation and release of descrete locations on GA property in order to meet the USNRC regulations for release to unrestricted use.
5
- 2. 0 Scope-1 The scope will include examination and review of: statistics and procedures, instrumentations and calibration, data and evaluation
.. documentation and verification.
13) 3.0 Statistics and Procedures n
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Statistics that are used shall be checked for accuracy and applicability.
The proceduro ;used shall be current.
4.0 Instrumentation and Calibration All instruments shall be mechanically and electronically stable. The m..
calibration shall be with applicable standards and be traceable to NBS
'I Standards.
- 5. 0 Data. Evaluation, Documentation and Verification s
All data and its documentation anall be maintained as to be retrievable and traceable.
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